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Discipline disparities have been widely reported in the K-12 school system, yet little published research has investigated disparities in higher education. Drawing upon student conduct data from a large statewide system of higher education, we use the Focal Concerns and Loose Coupling perspective to break the student conduct process into four stages and determine where bias may enter the Student Conduct process. Preliminary results indicate Asian respondents are more likely to be charged with policy violations, females are more likely to be assigned a warning, and Black respondents are suspended/expelled at higher rates.